Lynch, Loretta 072716 .pdf

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July 27, 2016
Ms. Loretta Lynch
Attorney General of the United States
Department of Justice
950 Pennsylvania Avenue, NW
Washington, DC 20530-0001
Dear Attorney General Lynch,
We write to you as music creators and as representatives of organizations representing
more than half-a-million songwriters, lyricists, composers, performers and producers
around the world whose ability to earn a living from our creative work has been put in
jeopardy by the recent recommendations of the Antitrust Division of the Department of
Justice. We respectfully request that you personally review the actions of the Division,
keeping in mind that these decisions impact not only the corporations the Division seeks
to regulate, but music creators throughout the world.
We understand the Department's mandate to enforce the provisions of the Antitrust law
and to take such action it deems necessary to do so. That said, there are many options
open to the Department that can prevent anti-competitive behavior, while preserving the
ability of songwriters and composers to freely write the music the world loves. We
believe the Antitrust Division's proposal for 100% or "full work" licensing is not one of
those options.
The Division's proposal is a naive and dangerous plan that attempts to regulate the
behavior of a few corporate entities by fundamentally altering the landscape for everyone
involved in the creation of music. The resulting impact will not be mere “collateral
damage.” It will cause serious direct, immediate, and lasting harm to music creators and
hamper the creation of music itself.
The Division attorneys with whom we have communicated for the past two years are
fond of saying that everyone they regulate complains, but that eventually people find
ways to cope with the Division's decisions. That may be true for the corporations with
which the Division has experience. It is not true for music creators and we believe that
such statements are evidence that the Division's lawyers do not understand, and appear to
have little concern for, how music is created. We are not multinationals making
refrigerators or operating television stations. We are not airlines or telecoms. We don't
have stockholders. We have ourselves, our talent and usually a few people with whom we
work to help us realize our creative vision.
Music is a collaborative venture between and among creative people. Most of today's
music is being knit together by talented teams of writers, performers, and producers, all
of whom contribute to the final work. This method of music creation, which has produced
one of our nation’s greatest cultural assets and one of its most successful exports, will be

forever diminished if the Division's recommendations for “full work” licenses are
We urge you to consult with experts in the field of music creation and to conduct an
independent review of the Division's activities and proposals before you permit this illconceived plan to progress any further. The fate of hundreds of thousands of music
creators and the future of the cultural landscape they have created are in your hands.
Council of Music Creators (CMC)
European Composer & Songwriter Alliance (ECSA
The International Council Of Music Authors (CIAM)
Screen Composers Guild of Canada (SCGC)
Society of Composers & Lyricists (SCL)
Songwriters Association of Canada (SAC)
Songwriters Guild of America (SGA)
Songwriters of North America – Los Angeles Branch (SONA)


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